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V1622-24 ·3 July 2024 ·consulta-vinculante Medium impact
Tax

Causality required for special regime under article 93 LIRPF

A resident in Sweden asks whether she can benefit from the special tax regime for non-residents after setting up a Spanish company and becoming its administrator. The DGT states that access to this regime requires proof that the move to Spain is directly linked to becoming an administrator.

In 6 key points

How it affects those involved

Non-residents must demonstrate a direct causal link between their move to Spain and their role as administrator to qualify for the special tax regime.

Lifecycle

2024-07-03PublishedPublished in the BOE
Official text Based on BOE data (boe.es). Information, not advice.

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This analysis is informational only and does not constitute legal advice or create a client-adviser relationship. BM Consulting.
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